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Comment 196 for ZEV 2008 (zev2008) - 45 Day.

First NameLisa
Last NameRosen
Email Addresslrosen@eesolar.com
AffiliationOffice Manager
SubjectDon't Eviscerate ZEV Mandate
Comment
1020 Marvista Ave
Seal Beach, CA 90740
March 24, 2008

RE: Retain Strong ZEV Mandate

To Mary Nichols and CARB Board members:

Please follow the resolution of the board of May 2007. 
Do not reduce the requirements for clean vehicles.

Requirements can be reduced if there is a necessity to do so, but
once they are gone, restoration is a tedious process. Under both
AB 32 and the ZEV mandate it would be better to allow your agency
the possibility of effective regulation, rather than diminishing
implementation. Research with fuel cells has not yet yielded any
significant breakthroughs. Manufacturers should be allowed the
option of producing the vehicles that will comply. If vehicle
research is successful, but infrastructure questions arise,
leaving the requirements in place with an alternative path to
compliance strengthens the likelihood that both CARB and auto
manufacturers will continue their efforts with the urgency of a
serious deadline in place.

If Fuel Cell and Hydrogen Vehicles can not be brought to market,
with the postponements previously allowed, the manufacturers
should be allowed to instead produce (and sell) BEVs of the
quality that past compliance produced.

Walter Puetz of Mercedes Benz wrote that his company anticipated
that they could bring 100,000 fuel cell cars to market by 2015, at
a cost equal to that of a diesel hybrid. If this is the case, it is
one more argument for leaving the present regulations in place.
 
Postponing difficult decisions makes them even more difficult as
time passes and options diminish.

The proposed silver-plus credit for plug in hybrids should not be
implemented as recommended. It would not be effective in promoting
CARB goals. A vehicle that can only run ten miles  (at 18 mph)
would not provide much in the way of clean air benefits.  The
vehicles for which this technology is proposed sound very
unattractive to the drivers who care about vehicle efficiency and
clean air. BEV technology ten years ago was better than this. Any
vehicle in this category should be able to operate in Electric
mode at full speed. There should also be a requirement that the
vehicle not be equipped with software that prevents any addition
to the battery pack.

Manufacturers should not be given credit for any vehicle unless it
is sold to the public.

The citizens of California should be given an accounting of the
effectiveness of this program: the actual number and type of
vehicles on still on the road.

The travel provision--giving credit for vehicles sold or placed in
other states--is not a good idea.

Yours truly

Lisa Rosen


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Date and Time Comment Was Submitted 2008-03-24 21:32:59

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